Privacy Policy

Curio Labs Limited (“Curio”, “we”, “us” or “our”) respects your privacy and takes the protection of your personal information very seriously. This policy describes the information we hold about you, how it is used and with whom we may or may not share it. It also informs you about your privacy rights and how the law protects you.

This Privacy Policy covers the curio.io™ service, including its mobile application, website, any other applications, websites and/or home audio channels made available by Curio. We are not responsible for the privacy practices on any applications, websites or channels which are not controlled by curio.io. For example, we do not exercise control over other sites that our service links to, on which you can read content about our service. Clicking on links on our website or enabling those connections may allow third parties to collect or share data about you. When you leave any curio.io application or website, we encourage you to carefully review the privacy policies on all other websites that you visit or applications that you use.

Curio Labs Limited is the controller of the personal information it processes and our Director is responsible for overseeing questions relating to this policy. If you have any questions about this policy, or wish to exercise your privacy rights, please contact:Our Director at listen@curio.io.

You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), which is the supervisor authority in the UK for data protection issues. We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

Changes to the privacy notice and your duty to inform us of changes

This privacy policy was last updated on 24 May 2018. Please contact us if you wish to see old versions of this Privacy Policy.

It is important that the data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

Personal data that we collect

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We may collect, use, store and transfer information about you which we have grouped together as follows:

1. Identity Data including your name
2. Contact Data including your email address, telephone number and billing address
3. Financial Data including bank account and payment card details and method of payment preference
4. Transaction Data including details about payments between us and other details of products and services you have purchased from us
5. Technical Data including your IP address, your login data, device details, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access any of our services
6. Profile Data including your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses
7. Usage Data including information about how you use our website and services including your track selection, duration of listening, listening history, your library and search queries
8. Marketing and Communications Data including your preferences in receiving marketing from us and your communication preferences.

We also collect and use Aggregated Data to track the use of our services. This data is derived from your personal data but is not considered personal data from a legal point of view as it does not directly or indirectly reveal your identity. For example, we may aggregate your Usage data to understand how popular articles are.

If you fail to provide personal data

Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you our services). In this case, we may have to cancel our service to you but we will notify you if this is the case at the time.

How is your personal data collected?

We use different methods to collect data from and about you including through:

1. Direct interactions. You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us online, by phone, email or otherwise. This includes personal data you provide when you:
   1. apply to trial our services;
   2. create an account with us;
   3. subscribe to our service or publications;
   4. request marketing to be sent to you;
   5. enter a competition, promotion or survey; or
   6. give us some feedback.
2. Automated technologies or interactions. As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We may collect this personal data by using server logs and other similar technologies.
3. Third parties or publicly available sources. We may receive personal data about you from various third parties as set out below:
   1. Technical Data from the following parties:
      1. analytics providers based within or outside the EU;
      2. search information providers such as Google based inside OR outside the EU.
      3. Contact, Financial and Transaction Data from providers of technical, payment and delivery services such as Stripe based inside OR outside the EU.

Use of information

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

1. where we need to perform the contract we are about to enter into or have entered into with you
2. where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests and where we need to comply with a legal or regulatory obligation.
3. Generally we do not rely on consent as a legal basis for processing your personal data other than in relation to sending direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us at listen@curio.io.

Purposes for which we will use your personal data

We have set out below, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data for any of the purposes set out below:

1. To register you as a new customer
2. To process and deliver your order including:
   1. Manage payments, fees and charges
   2. Collect and recover money owed to us
3. To manage our relationship with you which will include:
   1. Notifying you about changes to our terms or privacy policy
   2. Asking you to leave a review or provide feedback
4. To administer and protect our business and services (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)
5. To deliver relevant content and services to you and measure or understand the effectiveness of the service we provide
6. To use data analytics to improve our products/services, marketing, customer relationships and experiences
To make suggestions and recommendations to you about content that may be of interest to you
If you would like to know more about how and why we use personal data, please contact us at listen@curio.io

Marketing

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. We have established the following personal data control mechanisms:

Promotional offers from us

We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).

You will receive marketing communications from us if you have requested information from us or purchased services from us or if you provided us with your details via our website and, in each case, you have not opted out of receiving that marketing.

Third-party marketing

We do not share or sell any personal information or information that may personally identify you to any third party.

Opting out

You can ask us to stop sending you marketing messages at any time by contacting us at any time at listen@curio.io

Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product/service purchase, product/service experience or other transactions.

Change of purpose

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

Disclosures of your personal data

We may have to share your personal data with external third parties for the purposes set out in the table above. These third parties may be:

1. service providers acting as processors based within The EU and in The United States of America, who provide IT and system administration services.
2. professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers based in The UK who provide consultancy, banking, legal, insurance and accounting services.
3. HM Revenue & Customs, regulators and other authorities based in the United Kingdom] who require reporting of processing activities in certain circumstances.
4. Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

International transfers

A few of our external third parties are based outside the European Economic Area (EEA) so their processing of your personal data will involve a transfer of data outside the EEA.

Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

1. where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe. For further details, see European Commission: Model contracts for the transfer of personal data to third countries;
2. where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between the Europe and the US. For further details, see European Commission: EU-US Privacy Shield.

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.

Data security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

Data retention

How long will we use your personal data for?

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

Details of retention periods for different aspects of your personal data are available in our retention policy which you can request from us by contacting us.

If you have any questions relating to this Privacy Policy, do not hesitate to contact us at listen@curio.io.

Legal Rights

You have the right to:

Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data's accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

If you would like to make any of the above requests, including any request for erasure of your personal data, please write to us at listen@curio.io.

More detail on lawful bases